In the Williams v. Gaylord case of 1901, the U.S Supreme Court was tasked with determining whether a contract for sale of land in Michigan to a British subject violated federal law prohibiting foreign ownership of land. The plaintiff, Williams, sought to recover payments made under this contract on grounds that it was illegal and void. However, the defendant argued that there were no such prohibitions at either state or national level when the contract was signed in 1883. The court ruled in favor of Gaylord (the defendant), stating that while Congress had indeed passed laws restricting foreign individuals and governments from acquiring public lands within certain territories and states after 1887; these restrictions did not apply retroactively nor did they cover private transactions like those between Williams and Gaylord. Therefore, since there were no legal barriers preventing foreigners from owning property at both state or federal levels during time period when their agreement took place; their deal could not be considered unlawful or invalid based on later legislation. As such, any payments made by Williams towards purchase price would remain non-refundable as per terms stipulated within their original sales agreement.

In the dissenting opinion for Williams v. Gaylord, it was argued that the majority's decision to uphold a tax on inheritances violated constitutional principles of equal protection and due process. The dissent contended that inheritance is not income but rather a transfer of property rights from one person to another upon death. Therefore, taxing it as income unfairly penalizes those who receive an inheritance compared to others who acquire wealth through other means such as earnings or investments. Furthermore, they asserted that this type of taxation could lead to double taxation since the inherited property may have already been taxed when initially acquired by the deceased person. They also raised concerns about potential abuses in determining taxable value and suggested that this could infringe on individuals' right to due process under law.